As Meaningful Use Stage 2 was recently finalized, it is imperative that eligible practices and hospitals are ready to attest consequently receive the financial incentives. In Part I and Part II of this Meaningful Use Guide article series, we gave an overview of some important dates and changes, as well as a comprehensive look at the Stage 2 objectives and measures.

The final part of this article series focuses on Frequently Asked Questions to help clarify any lingering questions or concerns about attesting to Meaningful Use.

Part III: Frequently Asked Questions

If I already did a Security Risk Analysis, do I need to do it again?

According to CMS, the risk analysis can be done anytime from January 1 to the last day of your reporting period for that year.

I was supposed to be in Stage 1 for 2015. Am I affected by these modifications?

Yes. Eligible Providers are now in Stage 2 of Meaningful Use, but if you were previously in Stage 1, you are now in “”Modified Stage 2.” However, if you were trying to meet Stage 1 measures that no longer exist in Stage 2, check the CMS website to see if you qualify for an exclusion.

When can I attest for Meaningful Use 2015?

Eligible Providers were able to attest for a 2015 90-day reporting period starting on January 4, 2016. The new attestation deadline was March 11, 2016.

What do I do if I didn’t meet my objectives last year but I’m trying again this year?

If you succeed in meeting MU you will receive the financial incentives in line with your First Payment Attestation. However, eligible providers who did not attest to MU successfully in 2015 will receive a 3% penalty in 2017. Eligible providers who do not attest to MU successfully in 2016 will receive a 4% penalty in 2018.

However, if you were not able to attest due to the late release of the final rule, you could be eligible to apply for a hardship exemption, avoiding financial penalties. Other examples of not being able to meet MU range from lack of reliable internet to the inability to find a federally certified EHR. For more information on how to apply for a hardship exemption see the CMS website and apply by July 1, 2016.

What does a “blanket exception” mean?

CMS has cut down the amount of information needed to complete an application for a hardship exemption and created a centralized application. Further, several providers can be listed on the same hardship exemption application, given that they all have the same hardship listed on the request. Take a look at the application and the application instructionsfor more details.

As a provider, what do I do if I wanted to attest for 2015 but the old measures?

Consider applying for an exclusion if you were ready to attest, but did not prepare to report additional registries. If you already registered, tested, or began to submit your data, do not start over. Instead you can attest to the item that best aligns with your current level of engagement (either registration, testing and validation, or production).

If I met my objectives last year and am applying for MU again, do I need to do anything differently?

Congratulations for meeting MU in 2015! Continue to stay up to date with any changes to MU regarding objectives and attestation date changes so you can be best prepared for the next reporting year.

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John Deutsch, a health IT entrepreneur and business owner for 13 years, is the CEO and founder of Medical Web Experts and Bridge Patient Portal. His extensive experience in Healthcare IT includes business development, software development, patient portals, mHealth, patient engagement, HIPAA, electronic medical records, web development and internet marketing. He also co-founded EMR Experts, an EHR consulting firm.

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John Deutsch, a health IT entrepreneur and business owner for 13 years, is the CEO and founder of Medical Web Experts and Bridge Patient Portal. His extensive experience in Healthcare IT includes business development, software development, patient portals, mHealth, patient engagement, HIPAA, electronic medical records, web development and internet marketing. He also co-founded EMR Experts, an EHR consulting firm.